OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 22, 1998

Mr. Larry N. Taylor
LNT Enterprises, Inc.
6607 Napoli Rd.
Camp Springs, MD 20748

Dear Mr. Taylor:

This is in response to your letter of May 1, with regard to your concerns about the storage and transport of windshield solvents, a mixture of 35% methanol and 65% water.

In your letter, you indicated that the Occupational Safety and Health Administration's (OSHA's) regulation, 29 CFR 1910.106, requires that such a mixture (Class 1C-flammable) be stored in a metal container.

Please note that due to progressing technology and information available after the issuance of OSHA's standard, OSHA has approved the usage of large plastic storage containers and drums for the storage of flammable liquids. These containers, however, must be approved by either the Department of Transportation, or they must have been approved by a Nationally Recognized Testing Laboratory, in order to meet the intent of the standard.

Therefore, the Department of Transportation's acceptance of the plastic drums does not represent any conflict with current OSHA policy. In other words, you may store your 35% methanol mixture in a plastic container, as OSHA would not require you to dispense the contents of the plastic container into a metal container.

Thank you for bringing your concerns to our attention. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.


John B. Miles, Jr., Director
Directorate of Compliance Programs